TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... beneficial owner of the interest the tax so charged shall not exceed 1 [ 10 per cent ] of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, (a) interest arising in a Contracting State shall be exempt from tax in that State, provided it is derived and beneficially owned by : (i) he Government, a political sub-division or a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts, and in particular, income from Government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shment or a fixed base in connection with which the indebtedness in which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between payer and the beneficia ..... X X X X Extracts X X X X X X X X Extracts X X X X
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